SEC says it will respect well-reasoned revenue judgments

The Securities and Exchange Commission has signaled it doesn’t plan to get into ticky tacky spats with companies over the numerous detailed judgments they must exercise as they follow new revenue recognition rules beginning next year.

“We want to avoid regulating the more nuanced aspects of this standard one company at a time,” said Cicely LaMothe, an associate director in the Division of Corporation Finance at the SEC. The division plans to coordinate closely with the Office of the Chief Accountant in reviewing company filings as financial statements beginning rolling out next year reflecting the massive change in how to recognize revenue.

That doesn’t mean the SEC will overlook plain errors in applying the guidance or disclosures that are entirely missing, LaMothe said, but the staff has collectively concluded that it won’t be efficient or effective for the review and comment process to get into the weeds of preparer judgments.

Sagar Teotia, deputy chief accountant in the SEC’s OCA, said reasonable judgments by preparers will be respected, “to the extent you do something reasonable.” That means preparers will be expected to show that they’ve gathered all the relevant facts, performed the necessary research, considered all the possible alternatives, and conducted a thorough analysis in arriving at those judgments, he said.

The OCA even put its intentions in writing as part of a statement from the office of Chief Accountant Wes Bricker summarizing a number of accounting issues. “OCA has accepted (and will continue to accept) reasonable judgments in consultations on the new GAAP standards,” the statement says.

Sue Cosper, technical director at the Financial Accounting Standards Board, said the standard certainly requires judgment, but so does the current body of GAAP on revenue recognition. “There’s judgment today as you think about the determination of when you have a deliverable, the timing of revenue recognition, and the transaction price,” she said. “There’s judgment today, and there will be judgment tomorrow. That doesn’t really change.”

The massive new standard on revenue recognition takes effect for public companies on Jan. 1, 2018. Cosper said FASB staff has fielded many technical inquiries on the requirements of the standard as the board’s Transition Resource Group wound down its work taking and answering technical questions. “Since Nov. 1, our technical inquiries are starting to tail off as get closer to Jan. 1,” she said.